Grievance & Whistleblower Protection Policy

Last Updated: 4^th June 2026
Effective Date: 4^th June 2026
Applies To: Employees, Clients, Suppliers, Contractors, Partners, and the General Public
Contact: Please send all grievances and whistleblower reports to our Chief Operating Officer at: info@consultus.com (Subject: “Confidential – Grievance/Whistleblower”)

1. Purpose

Consultus International Group Limited (“Consultus”) is committed to operating with the highest standards of ethics, transparency, and accountability. This policy outlines how stakeholders may raise grievances or report misconduct and the procedures we follow to address these concerns. It also outlines our strict protections for whistleblowers and our zero-tolerance approach to retaliation.

Scope

This policy applies to all internal and external stakeholders, including but not limited to:

• Employees (full-time, part-time, contractors)
• Clients and customers
• Suppliers and vendors
• Business partners
• Community members or the general public

2. Grievance/Complaint Mechanism

2.1 What Can Be Reported

Consultus encourages the reporting of concerns related to:

• Ethical misconduct (e.g., fraud, corruption, bribery)
• Environmental violations or unsustainable practices
• Human rights violations or abuse
• Unsafe or illegal workplace behaviour
• Breaches of our policies, codes of conduct, or third-party obligations

Excluded Issues:

Issues not related to the company’s conduct, or internal HR matters not relevant to third parties, may not be investigated through this process.

2.2 How to Submit a Grievance

You may raise a grievance by sending an email to the Chief Operating Officer at info@consultus.com (Subject: “Confidential – Grievance/Whistleblower”).

The reporting message should contain details such as a description of the violation, date, time, location, and any supporting evidence.  You may choose to remain anonymous.

3. Grievance Handling Process

3.1 Grievance Handling Process

Stage 1. Acknowledgement
Timeline: Within 3 business days
A confirmation will be sent to the complainant (unless submitted anonymously).

Stage 2. Initial Review
Timeline: Within 10 business days
Assess admissibility and assign a Case Manager.

Stage 3. Investigation
Timeline: Within 30 calendar days
A thorough and impartial investigation. Updates provided every 10 business days.

Stage 4. Resolution
Timeline: Varies by complexity (target within 45 days)
A written outcome will be shared. If grievance is not accepted, a clear explanation will be provided.

3.2 Responsibilities

• Case Manager: Assigned to each grievance; manages communication and coordination.
• Investigative Team: May include internal or external experts, depending on the issue.
• Senior Leadership: Reviews high-risk or sensitive cases.

3.3 Actions Against Third Parties

If the investigation finds that a third party (e.g., vendor, supplier, client) has acted unethically or illegally, Consultus may:

• Terminate the contract or engagement
• Report the matter to regulatory authorities
• Prohibit future collaboration
• Disciplinary Procedure for Staff

Our aim is to support all employees in meeting the standards expected of them, fostering an environment where issues are resolved quickly and informally whenever possible. This section outlines our approach to handling situations where further action may be needed.

4. Disciplinary Procedure for Staff

4.1 Principles

• Fairness: Everyone deserves to be treated fairly and respectfully.
• Clarity: We will clearly explain any concerns and the improvements needed.
• Support: We aim to assist employees in meeting expectations through guidance and support.

4.2 Steps in the Disciplinary Process

1. Informal Discussion – If there’s a concern about your performance or behaviour, your manager will first talk to you informally. This is a chance to understand any issues and how you might resolve them together.

2. Informal Discussion 2 – If the situation doesn’t improve, one more informal discussion.

3. Formal Meeting – If the situation doesn’t improve, or if the issue is more serious, a formal meeting will be scheduled. You’ll receive a clear explanation of the issue beforehand and you can bring a colleague for support. This meeting is a chance to discuss the situation, make your case, and explore solutions.

4. Outcome – After the meeting, we’ll take some time to make a decision, considering everything discussed. We’ll let you know the outcome in writing, which might be a warning to improve behaviour or performance. We’ll explain what needs to change and how we can support you in making these changes.

5. Follow-Up – We’ll schedule follow-ups to review progress and provide ongoing support. If there are still issues, we might need to meet again, and further actions, such as additional warnings or other measures, may be considered.

4.3 Appeal

If you disagree with a disciplinary decision, you have the right to appeal. Just let us know in writing within a week of the decision. We’ll arrange for a manager not involved in the original process to review it and provide a final response.

4.4 Documentation

To keep everything transparent, all formal procedures and decisions will be documented and shared with you. This ensures both parties have a clear understanding of what was discussed and agreed upon.

5. Whistleblower Protection Policy

5.1 Protection from Retaliation

Consultus strictly prohibits retaliation against anyone who reports a concern in good faith, regardless of the outcome of the investigation.  Retaliation includes, but is not limited to:

• Termination or demotion
• Harassment or intimidation
• Contract cancellation
• Denial of future work or business

5.2 Consequences for Retaliation

• Employees: Subject to disciplinary action, up to and including termination.
• Suppliers/Vendors/Clients: Subject to contract termination and permanent disqualification.
• Partners: Subject to suspension or termination of business relationships.

5.3 Anonymity & Confidentiality

• Complainants may report anonymously through the grievance form or by omitting personal details in email or post.
• All reports are handled with strict confidentiality. Identities are only disclosed with consent or when legally required.
• Access to grievance details is limited to personnel involved in the investigation.

6. Communication and Updates

• Complainants (unless anonymous) will receive regular updates on the progress of the grievance.
• A summary of the findings and actions taken will be shared once the matter is resolved.
• In cases where the grievance is not investigated, a written explanation will be provided.

7. Policy Accessibility

This policy is publicly available at consultus-sustainability.co.uk/grievance-whistleblower-protection-policy/ and may also be referenced in our contracts, onboarding documents, and vendor agreements.

8. Review

This policy will be reviewed annually or in response to significant legal, regulatory, or organisational changes.